[Peetwo]

TAAAF backs the Iron Ring in the 24th running of the Embuggerance Cup - 

Got a feeling the following bit of scuttlebutt coming out of Can'tberra will dramatically change the odds of the 24th Embuggerance Cup...  

Fresh (with embellishments -   ) off the RRAT's ATSB inquiry webpage:

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Just so you don't think I made it all up...  : refer here - 6 The Australian Aviation Associations’ Forum (PDF 17 KB) 

Incoming me thinks?? - P2 

"I s'pect I just growed. Don't think nobody never made me."

Time was on my side today, it allowed me to plod my way through the entire ATSB report; top to bottom. If, as we must, set aside the appalling tangle which exists regarding the categorising of operation (a right buggers muddle); many of the points raised by ATSB have some validity. A decade ago in the USA CSF, FAA and NTSB dealt with a very similar situation, I believe in a very fair, open, transparent and equitable manner. There were questions of law, operational transparency and, importantly – accountability. Serious matters all.

What the vengeance, could he not speak 'em fair?

History is always on hand and brings some balance to the argument; for instance:-

ATSB (p, 25 - PDF) "Part of the consultation included the publication of a discussion paper DP1317OS – Safety standards for community service flights conducted on a voluntary basis’ in August 2014, for industry consideration and input regarding community service flights, and how they should be regulated under the new CASRs."

ATSB - "At the time (2003) Angel Flight was established, it indicated to CASA that there was an expectation that 250-300 pilots would be conducting approximately 800 flights per year when fully operational. As these flights were being conducted as private flights, and were expected to constitute a small percentage of this regulated sector, CASA considered the overall risk impact was negligible, and a formal risk assessment was not conducted."

ATSB - “In the period 2008-2017, an average of 1,686 flights per year were being conducted, and as at June 2017 a pool of 3,180 volunteer pilots were registered. Since that time (2003) other operators providing similar flights have also been established.”

That is quite a hike in numbers with the risk factors increasing in line; ATSB go on:-

ATSB - “The paper identified that there was a lack of visibility of the conduct of community service flights, which in turn prevented a more informed view for evidence-based decision making in this sector of the industry. It proposed 10 main options for consideration, ranging from administrative options through operational requirements, with the potential to combine a range of the proposed options, or consider additional options suggested through the consultation process.”

Fair and reasonable. With this level of activity some kind of operational safety data analysis would be of benefit to all parties concerned. Almost any kind of Safety Management System (SMS) can and will identify the ‘one off’ hiccup, the development of an ‘unsafe’ trend; or, an identifiable operational ‘grey area’. All good stuff and with luck ‘correctable’ before the unmentionable hits the whirligig. Stitch in time etc. CASA ran into a brick wall:-

ATSB – “The submissions received in response to the discussion paper highlighted strong opposition to the prospect of any regulatory involvement in the sector, indicating that community service flying would no longer be financially viable if any of the options were applied. Based on the submissions received, no regulatory changes were initiated, with the flights remaining as private operations with no additional regulatory requirements and no additional organisational-based risk controls.”

Perhaps, with 20/20 hindsight this was not the best road to travel. With up to 3,180 pilots available, a variety of aircraft, schedules to keep and the vagaries of weather; a data base would be helpful. Not many chief pilots would like to ride herd on an operation like that; no matter the license standards of the pilots. So, it’s just like Topsy said. -

Finally, we get to the sticking point. Why is there so much ‘fuss’ and Senators asking questions? Many don’t believe that the AF/CSF imbroglio is much more than a stalking horse for a much bigger animal. Behind the smiles and cooperation, there exists not only a deep, well founded mistrust of the regulator, but derision for the way in which the regulator manages aviation. Add a serious, demonstrable lack of confidence in the ATSB, particularly under Hood, and almost any ‘event’ will trigger the hostility, the peasants reaching for pitch forks and torches. The ever present hope of reform of regulator and regulation has long burned bright in the dark places of aviation. So, the question is M’lud, how much of the CSF backlash is actually generated by the pitiful ATSB report?

To answer that question we must look at the credibility of ATSB – as seen by those who have been amazed by the ease at which a PC answer has been, eventually,  provided and how often. We could ask the same question of CASA. Some of their past and indeed present actions have been met with anger, derision and a real rise in the distrust levels. These are facts; not faery tales I’ve whipped up to frighten the children.

Proof positive was provided today. TAAAF issued a statement. It should be able to stand alone, unchallenged as a righteous call. For, in essence it is a fair and reasonable call to bring in some form of controls, as much in CSF favour as anyone else’s. Much of what ATSB have stated and the CASA actions are fair and reasonable - but: and it is a big BUT; it will not be seen that way. Such is the schism of mistrust; TAAAF will be seen as catamite to CASA; Boyd branded a stooge and the divisions within the GA industry will deepen. Some will even say that that division was played for. But there is merit for the notion of an individual, dedicated 'category' for CSF operations. Makes perfect sense, get 'em legal, get 'em operationally uniform, give 'em a SMS - all good sensible stuff. Everyone should be behind a sane, sensible solution - Alas.............

Gloucester, we have done deeds of charity, made peace of enmity, fair love of hate, between these swelling wrong-incensed peers.

I say this M’lud: there are some very real, valid safety arguments being buried here. Lost in the swamps of Sleepy Hollow. CASA is distrusted, ATSB is compromised and the minister is played for Gods own fool. The world and it’s wife know this; industry know this. How much longer can government play at silly buggers. The problem Ostriches have was best explained in song.

The sexual life of the ostrich,
Is hard to understand,
At the height of the mating season,
It buries its head in the sand.
And if another ostrich finds it,
Standing there with its ass in the air,
Does it have the urge to grind it
Or doesn't it bloody-well care?

Hmm...yes but??

I agree with the context of your argument "K", however you will remember that we covered off on the previous CASA look at CSFs (ie 2014). This included what we both agreed was an excellent concept introduced by CASA the SRP (Sector Risk Profile), which apparently St Commode and his acolytes were not so keen on...

References:  St Carmode the guru of bureaucratic obfuscation of aviation safety?? & Aviation – and the poison chalice piss take within?  

..According to the Fort Fumble R&S webpage the SRP concept mysteriously stopped at the small aeroplanes transport sector. Ironically the last official SRP to be produced was countersigned by St Carmode when he was in the Acting CEO role. Less than 2 months later CC was to become the latest CEO/DAS of Fort Fumble and since that time there has been no more SRPs published, including the promised SRPs in the above QON??

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The "NOTE" above would seem to indicate that this 'sector analysis' concept is a recent innovation. However it doesn't take long to realise that this proactive regulator initiated concept has been in play since at least the 28/01/2015 - right click on pdf link HERE then click on properties, note date created. This places the 'sector analysis' concept at the very start of the brief period that Mark Skidmore was the CASA CEO.


Assuming that Skidmore was supportive of this sector safety risk analysis, his moniker on the bottom of the aerodrome sector analysis would seem to support this assumption, brings into play some other interesting parallels. -   

Rewinding to early 2015 it should be remembered that Skidmore was responsible for knocking the last CASA attempted Angel Flight embuggerance on the head (see previous post above):

CASA said on Friday people power had persuaded the regulator to maintain the status quo on how not-for-profit community service flights were regulated, with the present guidelines guidelines sufficient for now.

“We have listened to the feedback to CASA’s preferred option and we accept this is not the way to proceed,” Skidmore said in a statement.

“CASA is not proposing any changes to the existing regulatory requirements for community service flights at this time.”

    
Hmm...Shirley the previous CEO of CASA Mark Skidmore got his research (white hat) and stats crew to back up his decision with a relevant sector risk profile for Community Service Flights? And even if he didn't (due to the timing) Shirley St Carmode got his R&S crew to carry out the sector risk profile for the CSFs? 

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Hmm...kind of begs the question - was there ever a SRP created that encompassed 'community service flights' -   

Maybe this explains the current bizarre imbroglio from both Fort Fumble and the Hooded Canary's Avery, ie they missed the perfect opportunity to put in place a SMS type arrangement based on a mutually agreeable, co-operative SRP. As a consequence of this missed opportunity they (FF & HCA) are now attempting to play catch up in a most unagreeable, toxic way -  

On the subject of the totally (IMO) unprofessional Jeff Boyd signed TAAAF statement, I note that there was no parallel publicly released media statement. One has to wonder whether all of the remaining 13 members of TAAAF were made aware that this statement would be sent as a submission to the ATSB Senate Inquiry??

Also on the subject of TAAAF, I note that the ALAANZ (Aviation Law Association of Australia & New Zealand) is listed as  a TAAAF member. As a passing strange coincidence, it just so happens that one of the association's council members also works for the ATSB...  

            
Hmm...if that's not a conflict of interest I don't know what is...
MTF...P2